Ladies and Gentlemen: The Bank Policy Institute[1] and the U.S. Chamber of Commerce[2] submit this letter in response to the Board of Governors of the Federal Reserve System’s notice of proposed rulemaking relating to the Federal Reserve’s stress capital buffer requirement.[3] In light of the current flaws in the stress testing framework, which result in considerable volatility in the SCB and overall capital requirements, we urge the Federal Reserve to expeditiously adopt a final rule on ...
